One of the more common errors we come across in RMPs is the listing of earthquakes, floods, tornadoes and hurricanes as “major hazards”. I can say without hesitation that if your facility is in Omaha, NE that you should not be listing a “hurricane” as a “major hazard” associated with your process. But you very well may need to list “tornadoes” as a “major hazard” being that your in Omaha, NE (i.e. Tornado Alley); but even in Omaha you may not actually list “tornadoes” as a major hazard and I will explain why and when you should list these “major hazards” for your process(s) in this article…
Section 7.4.D of our Risk Management Plan requires us to select major hazards that were identified for the Program 3 process or part of the process as a result of our PHA(s). The RMP e-Submit User Manual states the following as to when we should be listing earthquakes, floods, tornadoes and hurricanes as a “major hazard”.
Earthquakes
Report earthquakes as a major hazard only if they occur or are likely to occur at your site such that you plan and design for them.
Floods (Flood Plain)
Report floods as a major hazard only if they occur or are likely to occur at your site such that you plan and design for them.
Tornadoes
Report tornadoes as a major hazard only if they occur or are likely to occur at your site such that you plan and design for them.
Hurricanes
Report hurricanes as a major hazard only if they occur or are likely to occur at your site such that you plan and design for them.
Now we can sort of reverse this logic and say that if we are building our process(s) to withstand or mitigate the consequences of these natural disasters then we should be addressing these event initiators in our PHA(s). It should be no surprise that if your process is located in the great state of California that “seismic design” is one of the major difference in the CalARP and EPA’s RMP and this would be a prime example of where “earthquakes” would be a “major hazard”.
But as I said earlier, merely because you live in a tornado prone area does NOT mean that you should be listing “tornadoes” as a major hazard. As the guidance states:
Report tornadoes as a major hazard only if they occur or are likely to occur at your site such that you plan and design for them.
I think most of us plan for server weather and even include severe weather in our emergency action plans; however, I am not quite sure I have ever seen any process that was “designed” for a tornado.
I have seen some plants that are decades old that are now located within an official “flood plain” vs. when they were built way back in the day they were NOT in a flood plain. These facilities most certainly need to be listing “floods” as a “major hazard”; especially if your RMP extremely hazardous substances is a “flammable”. Check out 1910.106(b)(5) Supports, foundations, and anchorage for all tank locations. There you will find section (vi) Flooded Areas, sections (a)-(v) that must be met when flammable liquid storage tanks are in “flood areas”. So here is an example of having to DESIGN and PLAN for floods that may impact your process.
Lastly it should go without saying that if our process is within 100 miles (my number NOT EPA’s) of a coast then we should be fully prepared for hurricanes and even design our emergency systems so that a hurricane surge does not take them all out. Many facility’s will build into their tank designs special anchoring methods. Having rode out three hurricanes/tropical storms at chemical facilities I can say first hand what good design and planning can do and how poor planning and no design will make for a long week, month, year!
So use the RMP e-Submit User Manual (2014 edition) when submitting or resubmitting our RMPs so that these plans can be as accurate as possible. Who knows, one day someone may actually use these plans as they were intended.